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Employee Loans

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  • #2390
    kowsley
    Keymaster

    There has been a little confusion in our loan processing area on how to process a loan request for an employee. The bank waives the origination fee and the transaction fee for employees of the bank. Given that the processor knows that these fees are waived at application, should they even be disclosed on the GFE? My first thought was no but as with everything RESPA related I second guess myself.

    Also, a recent employee loan request had title work waived as well; however, the processor wasn’t aware of this until right before the loan was to be closed. In this case, title work fees were disclosed on the GFE but should be $0 on the HUD, correct?

    Will these RESPA questions ever end?!!

    #2766
    JGo9
    Participant

    Kowsley,

    I think you are on the right track. If you know at the time of application that you are not going to charge a processing fee then I don’t think it should be included in the GFE. I looked through the Reg and some of the Q&A’s and didn’t find anything concrete on this.

    You are correct on the disclosing of the waived title work.

    The questions probably won’t stop unless the CFPB reworks RESPA. It’s a mess and there are way too may places to go to see if something is mentioned and you just hope HUD didn’t contradict their answers.

    #2767
    jholzknecht
    Keymaster

    An attorney waiving the title charges for an employee can be a significant violation of Section 8 of RESPA. This transaction should be reviewed and possibly reversed immediately.

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